Q546. Can facilities performing on-site acid gas injection estimate their emissions downward according to the provisions in 98.233(d)(11) for AGR unit emissions recovered and transferred outside the facility?

A546. Reporters performing on-site injection of acid gas may not adjust emissions downward. §98.233(d)(11) clearly states that you may only adjust emissions estimates downwards for emissions recovered and transferred OUTSIDE the facility.  Please see EPA-HQ-OAR-2009-0923-0582-31 in the Response To Comments (pages 1474 - 1476) http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_RTC_part2.pdf.


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